BALASUBRAHMANYAN, J.

In this appeal from the order of the Board of Revenue, the question relates to single point taxation under entry 4(b) and (d)(ii) of the Second Schedule to the Tamil Nadu General Sales Tax Act, 1959, before its amendment by Act 39 of 1973. Iron plates and steel plates are admittedly single point items. The assessee in this case sold sheet cuttings and plate cuttings in the course of its business. It is not quite clear whether the sheet cuttings and plate cuttings are out of steel plates or iron plates. But the assessee's contention before the assessing authority was that in either case they were not liable for multi-point sales tax. It was urged that the assessee had sold the iron and steel plates in the same form in which they were directly produced by the rolling mill.

The assessing authority, however, did not accept these contentions. The assessing authority held that the goods sold by the assessee were taxable at multi-point. The crucial findings of the assessing authority are as under :

"Their contention that the goods are sold in the same form in which they are purchased in the rolling mills is not acceptable. They have also not proved their cont